Forest Plan Revisions
September 26, 2019
Forest plans for the Inyo, Sequoia, and Sierra National Forests have been under revision since 2014. SFL and our partners have been advocating for the adoption of strong, conservation-focused plans. The forest plan for the Inyo National Forest is the first to be revised and finalized in the Sierra Nevada. We and coalition partners were actively engaged in all steps of the planning process, including the objection process which concluded with the release of the final plan on September 20, 2019. Overall, the revised plans include improved conservation for aquatic ecosystems, many at-risk species, Wild and Scenic Rivers, and roadless areas that have now been recommended as Wilderness Areas. The plan also is very forward thinking about fire and restoring this ecologically beneficial process to the plant communities of the eastside of the Sierra Nevada. We appreciate the willingness of Forest Supervisor Tammy Randall-Parker and her planning team to listen to our issues and in many cases to adopt (sometimes with minor revisions) the recommendations we proposed.
Our attention is still focused on the forest plans for the Sierra and Sequoia National Forests. On September 26, 2019, we and 16 coalition partners submitted comprehensive comments on the draft plans. These comments addressed a wide range of issues including conservation of aquatic ecosystems, old forests, roadless areas, and Wild and Scenic Rivers. The draft plans are very forward thinking about restoring ecologically beneficial fire. We supported this fire-focus in our detailed review of the draft plans and environmental documents. We also recommended additional conservation measures for aquatic ecosystems, old forests, and complex early serval forests. We are particularly concerned about lack of direction for many at-risk species and provide recommendations for California spotted owl, Pacific fisher, great gray owl, northern goshawk, willow flycatcher, Yosemite toad, Sierra Nevada red fox, various bats, California condor, Sierra Nevada bighorn sheep, black-backed woodpecker, western pond turtle, Central Valley steelhead – South Fork Merced population, and Greenhorn Mountains slender salamander.
We also worked with coalition members and groups connected with human-powered recreation interests to identify where conflicts might exist for the wilderness boundaries we were promoting, and revise the boundaries to limit conflicts with important outdoor recreation resources. The Forest Service included a draft of our collective recommendations as a new alternative (Alternative E) in the Revised Draft Environmental Impact Statement. Throughout the comment period we worked collaboratively with recreation stakeholders to fine tune these recommendations.
This engagement and coordination culminated in a letter from six recreation and conservation organizations supporting boundaries for ten recommended wilderness areas, the Backcountry Management Area land designation, and a joint recommendation to the Forest Service to affirmatively address the use of fixed anchors and their maintenance in existing Wilderness Areas. The work we undertook with these conservation and recreation organizations demonstrated to the Forest Service our collective willingness to work together to resolve user conflicts and make recommendations that could lead to reduced conflict in the future.
August 7, 2019
On June 28, 2019, the Sequoia and Sierra National Forests released their draft forest plans and revised draft environmental impact statement, initiating a 90-day public comment period closing on September 26, 2019.
Click here for a printable version of the most recent summary of key issues and recommendations.
Below, we provide a brief analysis regarding key issues in the plans.
Key Issues in the Sequoia and Sierra Revised Draft Forest Plans
The revised draft Sequoia and Sierra Forest Plans are analyzed in the Revised Draft Environmental Impact Statement (RDEIS) as the "Preferred Alternative B." We, the Sierra Forest Legacy coalition, urge the public to support "Alternative C" with the changes noted below. Alternative C recommends far more wilderness protection, proposes more acres of forest restored through prescribed and managed fire, and more riparian and meadow restoration than Alternative B.
What’s Good: The RDEIS identifies more than 800,000 acres of wilderness-quality lands across the two forests. The conservation-oriented Alternative C recommends over 452,000 acres of new wilderness. The new Alternative E also creates a Backcountry Management Area designation for roadless lands not recommended as wilderness. However, the Forest Service’s preferred Alternative B only adds a paltry 4,900 acres of new wilderness on the Sequoia NF and recommends no new wilderness on the Sierra NF despite hundreds of thousands of eligible acres.
Significant Improvements Needed:
• The Forest Service should adopt Alternative C or strengthen Alternative B to include more recommended wilderness areas on both forests, with an emphasis on low-elevation areas not typically protected by the wilderness system (see below for specific areas).
• Both plans should also apply Alternative E’s Backcountry Management Area designation to protect roadless areas not recommended for wilderness protection.
• Sequoia National Forest: Recommended wilderness areas should include the Golden Trout Wilderness Addition, Stormy Canyon, Oat Mountain, Cannell Peak, and the Domeland Wilderness West Addition, using boundaries developed by conservation groups to reduce conflicts with motorized and mountain bike trails (as displayed in Alt. E).
• Sierra National Forest: Recommended wilderness areas should include the Kings River-Monarch Wilderness Addition, Sycamore Springs, San Joaquin River-Ansel Adams Wilderness Addition, Bear Mountain, and Devil Gulch-Ferguson Ridge, using boundaries developed by conservation groups to reduce conflicts with motorized and mountain bike trails (as displayed in Alt. E).
Wild & Scenic Rivers
What’s Good: The Sequoia National Forest’s inventory of eligible rivers and streams was substantially improved in the 2019 draft plan. Eligible river miles increased from 75 miles in the 2016 draft plan to 341 miles in response to public comments. However, the Sierra National Forest’s inventory is a huge step backwards: eligible wild & scenic river (WSR) miles decreased by more than 500% from 640 miles in 2016 to just 35.5 miles in 2019. Public comments should commend the Sequoia NF for their expanded inventory and express concern about the substantially reduced WSR inventory on the Sierra NF. The eligible Wild & Scenic River inventory remains the same throughout all the alternatives.
Significant Improvements Needed:
• The draft plans should take a watershed approach to identifying eligible rivers and streams by identifying full streams as eligible rather than disconnected segments.
• Sequoia National Forest: The Forest Service should recognize additional eligible rivers including the North Fork Middle Fork Tule River and Rattlesnake Creek (North Fork Kern tributary).
• Sierra National Forest: The Forest Service should recognize additional eligible rivers including all 30+ miles of Dinkey Creek, the lower South Fork San Joaquin, the main San Joaquin below Mammoth Pool and Redinger dams, Granite Creek and Iron Creek (South Fork Merced tributary).
What's Good: The draft plans allow for prescribed fire and naturally-ignited wildfire managed for resource benefits, when conditions are right, across the landscape. The plans also recognize the benefits of prescribed fire on long-term smoke emissions and emphasize collaboration with air regulators to increase pace and scale of fire restoration.
• Set objectives for fire restoration that better match the ecological need of the landscape. Triple the amount of ecologically beneficial fire to 279,000 acres over the next 15 years.
• Include a realistic plan to increase prescribed fire capacity by establishing wildland fire crews solely dedicated to supporting prescribed fire rather than fire suppression.
• Increase focus on reducing surface and ladder fuels and using prescribed and managed wildfire as the primary fuels reduction and forest restoration tools.
Old Forests and Complex Early Seral Forests
What's Good: The draft plans recognize the ecological importance of mixed-severity fire in shaping the landscape.
Significant Improvements Needed:
• Adopt plan components in Alternative C that protect trees over 24” in diameter and a focus on removing surface and ladder fuels to across the landscape to better protect old forest habitat and increase resiliency.
• Include restrictions on salvage logging to protect most of the complex early seral habitat that is created by fire and other disturbances.
• Adopt the standards and guidelines in Alternative C for snag recruitment and retention.
Wildlife Species At-Risk
What's Good: Northern goshawk has been added as a Species of Conservation Concern. Protected areas have been added for great gray owl and northern goshawk. The approach to California spotted owl and fisher conservation has been improved but remains inadequate to support population viability. The plans now recognize that logging and grazing are threats to some at-risk species. Protections for Yosemite toad have been very much improved.
Significant Improvements Needed:
• Adopt plan components in Alternative C to protect more high-quality habitat (dense, large structured forests) for old forest dependent species like spotted owl, Pacific fisher, Pacific marten, great gray owl and northern goshawk.
• Add standards and guidelines to increase habitat quality of meadows historically occupied by willow flycatcher
• Adopt plan components in Alternative C to ensure high quality meadow foraging habitat is provided for reproductive great gray owls.
• Add conservation measures for species considered at-risk by experts and wildlife agencies; these include black-backed woodpecker and western pond turtle.
• Adopt Alterantive C that follows all recommendations made by scientists in the Fisher Conservation Strategy, including a 24” diameter limit.
• Add standards and guidelines, especially for logging and grazing, to ensure that habitat quality for at-risk species will maintain population viability or contribute to recovery.
Aquatic and Riparian Ecosystems
What's Good: The draft plans establish five Conservation Watersheds (2 on Sierra NF and 3 on Sequoia NF) to provide for continued high-quality water sources and the long-term persistence of at-risk species. Improvements were made to protections for riparian areas, meadows, and special aquatic features. Riparian areas now not considered part of the timber base.
Significant Improvements Needed:
• Adopt the Critical Aquatic Refuges identified in Alternative C to protect areas of high biodiversity and aquatic/riparian species that are at-risk.
• Adopt a standard that does not allow management actions, e.g., grazing, to impede the recovery of a meadow or other special aquatic feature.
• Adopt Alternative C to eliminate grazing in meadows that are degraded, poorly functioning, or that sustain at-risk species.
• Remove standard that allows 20% of a fen to be disturbed and eliminate grazing and other human-caused disturbance from seeps, springs, fens, and other special aquatic features.
• Adopt Alternative C to increase the number and acreage of meadows improved or restored.
What's Good: The draft plans recognize the importance of high quality forest recreation and the need for sustainable recreation opportunities that can be maintained into the future without harming the land. The draft plans recognize changes in use of recreation on the forests and the need for partnerships to sustainability manage recreation. In an attempt to better address emerging recreational interests, the plans also revise the Recreational Opportunity Spectrum.
Significant Improvements Needed:
• Provide quantifiable visitor use levels for each type of recreation and projections of how these levels would be affected by declining federal budgets.
• Include plan components, beyond desired conditions, to assure adequate protection and maintenance of national forest recreation areas.
• Better integrate recreation to other aspects of the plan such as fire and ecological integrity.
• Provide direction to improve education and interpretation so that all visitors better understand how to enjoy the forest responsibly.
• Commit to more robust partnerships with local communities, conservation groups and others to help achieve desired conditions for recreation.
• Improve Recreational Opportunity Spectrum (ROS) understanding by providing more detailed maps, including standards and guidelines for the management of each ROS allocation, and by adjusting some primitive and non-motorized boundaries to better protect inventoried roadless areas.
• Identify and address different seasons of recreation in the plan, including differentiating between summer and winter ROS. This can help lay the groundwork for winter travel planning.
For more information about Wilderness and Wild & Scenic Rivers, contact Steve Evans at CalWild at email@example.com or (916) 708-3155. For more information about Fire Management, Old and Early Forests, Wildlife Species at Risk, and Aquatic and Riparian Ecosystems, contact Jamie Ervin at Sierra Forest Legacy at firstname.lastname@example.org or (828) 403-0418.
June 28, 2019
The Sequoia and Sierra National Forests have released their draft forest plans and revised draft environmental impact statement, initiating a 90-day public comment period closing on September 26, 2019. Earlier versions of these draft documents were released in 2016. The agency has revised the draft documents to address changed conditions across the landscape, including extensive tree mortality, and other concerns brought up through public participation (see below).
The Forest Service will host a webinar on July 10 from 12-1:30 (Pacific) to provide an orientation to the planning process and draft documents available for review. Register here.
April 9, 2018
Read the SFL coalition's letter to the Sierra and Sequoia National Forests' supervisors, in support for protection of roadless areas and priority Recommended Wilderness Areas. The letter summarizes the culmination of many meetings with a variety of people and groups with an interest in conservation of the Sierra Nevada, and working out possible conflicts with other user groups. It is a refinement of our earlier recommendations, both in 2016 and 2017, and more clearly defines five highest priority areas for recommended wilderness areas as well as areas we suggest for backcountry management areas (BMAs).
August 11, 2017
Read the SFL coalition's letter to the Inyo National Forest regarding the "preview of plan components" that was released, in regards to four topic areas: Sustainable Recreation, WIld and Scenic Rivers, aquatic conservation, and species of conservation concern.
June 16, 2017
Read a summary of our coalition recommendations for forest plan components and content that we think are important to include in the revised draft forest plans for the Sierra and Sequoia National Forests. This is a summary of comments submitted August 25, 2016 (see below).
May 22, 2017
Read our coalition's recommendation letter to the Inyo National Forest.
The Forest Service has recently released timelines for the upcoming forest plan revisions now beginning for the Eldorado National Forest and the Stanislaus National Forest. The Eldorado NF also has a webpage now up with some background materials available for viewing, including an introductory video.
August 25, 2016
At the links below, download and read our coalition comments on the draft EIS and forest plan revisions for the Sequoia, Sierra, and Inyo National Forests. This was a huge effort made possible because of the deep commitment, dedication, and expertise of a crack group of core activists on our team. Thousands of pages of (frequently highly technical) documentation had to be carefully read through, vetted, and analyzed in order to identify the many problem areas in the agency's management plans.
Sadly, the DEIS and plans are a big disappointment, and we know the Forest Service can do--and should have done--better. Because of the many omissions and inaccuracies, we have asked for a revision or supplement to the draft plans. In many instances, the findings of leading scientists in their fields, as well as the agency's own scientists, were ignored or simply left out. Further, the massive tree mortality event now taking place throughout the Sierra Nevada, but most notably in the southern end of the range, due to drought and bark beetle epidemic, was not addressed at all--not even mentioned.
The agency has utterly failed to produce a scientifically credible representation of the environmental conditions of the region.
The first link below takes you to the Sierra Forest Legacy coalition's main comment letter, followed by four attachments containing exhibits I -XII. Part 2 lists the attachments.
Part 1. Main comment letter (4.3 MB)
Part 3. Exhibits VIII - IX (8.7 MB).
Part 4. Exhibit IX - XII (Maps (10.7 MB).
Part 5. Exhibits XII (continued) (4.4 MB)
June 21, 2016
Here are a couple of activist tools that can help to circulate information about the key issues involved in the forest plan revisions. The Sierra Club has produced the Citizens' Guide to Protecting the Inyo, Sierra and Sequoia National Forests, and our coalition also has a one-page fact sheet available for printing. Please share these links widely with friends and colleagues interested in participating in helping the Forest Service to make the best science based, conservation focused decisions to protect our precious public resources.
Download the Sierra Forest Plan Revisions Fact Sheet (Updated 6-27-16).
May 19, 2016
The Forest Service has released the draft forest plan revisions and draft environmental impact statements for the Inyo, Sequoia, and Sierra National Forests. The documents can be accessed at this website. The official 90-day timeline for submitting comments to the agency is determined by the publication date in the Federal Register, May 27, 2016; comments must be received by the agency by August 25, 2016. Instructions for submitting public comments electronically are found on the website, or click here. There will also be several opportunities to participate in discussions with the Forest Service at public meetings, and comments may be submitted directly there.
The meeting places and times are posted here.
Here, you will find comments and letters we've provided recently to the Forest Service relating to the early adopter plan revisions (Inyo, Sequoia, and Sierra National Forests).
February 1, 2016 Comments on draft list of Species of Conservation Concern
February 1, 2016 Wilderness Evaluation Process and Areas Identified for DEIS Analysis
February 1, 2016 Comments on Wild and Scenic River Evaluation
October 30, 2014: Comments on Wilderness Evaluation Process
September 29, 2014
Today Sierra Forest Legacy and our coalition partners submitted scoping comments on the NOI for forest plan revisions for the Inyo, Sequoia, and Sierra National Forests. Coalition partners included American Rivers, California Native Plant Society, California Wilderness Coalition, Defenders of Wildlife, Friends of the River, Mono Lake Committee, Pacific Rivers Council, Sierra Club, Western Watersheds Project, and the Wilderness Society.
The following five files were part of the comment package and can be downloaded here:
For reference to the comments on the proposed action, you may also want to review SFL et al comments on the "draft forest assessment" for each of the three forests:
Also, be sure to review the history for the process, and all the relevant documents, available on the planning pages for each forest here on the SFL website: Inyo, Sequoia, and Sierra National Forests. Quick link to these pages in the column to your right under "Plan Revisions Pending."
August 29th, 2014
Today the Federal Register published the Forest Service's Notice of Intent to prepare an environmental impact statement for the joint forest plan revisions for the Inyo, Sequoia, and Sierra National Forests. Download the NOI here, and review all of the scoping materials and maps at this FS planning website for the three early adopter Sierra Nevada forests. The draft EIS and plan is expected to be completed in the Spring of 2015; the revision is expected to be completed in the Spring of 2016. Comments from the public will be accepted until September 29, 2014.
Click here to go to the FS planning website to download all the documents.
June 30, 2014
Read our coalition's comments on the revised Need for Change and supplement.
The Forest Service released a supplement to the revised Need for Change document announced on May 20th. Additional information about the meetings and the associated documents are available at the Forest Service planning website.
The Sierra, Sequoia and Inyo forest plan revisions will be completed through the development of one environmental impact statement. The final EIS will result in three separate Records of Decision and three separate forest plans. Forest Supervisors will remain the responsible officials for making decisions on their specific forest plans.
For forest-specific information, please contact that forest directly:
- Sierra NF: Dirk Charley at (559) 297-0706, Extension 4805 or email@example.com
- Sequoia NF: Maria Ulloa at 559-784-1500 or firstname.lastname@example.org
- Inyo NF: Deb Schweizer at 760-873-2427 or email@example.com
March 27, 2014
Forest Service postpones forest plan revision timeline
Amid concerns among our coalition that the Forest Service was moving too quickly with plan revisions, the agency announced today a new plan revision schedule. Read our letter, here, and the Forest Service press release, here.
December 30, 2013
The final Forest Assessments have now been completed for the three "early adopter" forests, the Sierra, Sequoia, and Inyo National Forests. A single EIS will be prepared for all three forests. The agency created a "Preliminary Need for Change" document to lay the groundwork or theme for the plan revisions, and "identifies the areas that need to change in management direction outlined in the current plans." Click here to read SFL coalition comments on the Need for Change document. Workshops will be held in Bishop, Bakersfield, and Fresno to discuss the final assessments, preliminary "need for change" proposal, and plan revision process.
Download the final documents and public workshop announcements at this link. You can also learn more by visiting links to the three early adopter forests in the column on the right.
September 10, 2013
The Forest Service announced today that the agency has decided to prepare a single Environmental Impact Statement (EIS) for the Forest Plan Revisions for the Inyo, Sequoia, and Sierra National Forests. The purpose is to streamline the analysis process.
Be sure to check for the latest information from each of the three "early adopter" forests now undergoing forest plan revision, in the links to your right.
The Region's Draft Bioregional Assessment is now complete (May 23, 2013). The goal of the assessment is to take a landscape-level look at trends and conditions prior to the individual forests' plan assessments, in order to provide information at a broad scale that creates context beyond individual forests' boundaries. It includes both agency and public feedback on the same 15 topic areas that each of the early adopter forests are now compiling for forest plan revisions, as required by the 2012 planning rule. It is also informed by the January 2013 regional Science Synthesis (see below). Comments were accepted on the draft until June 15, 2013. Read Sierra Forest Legacy's comments on the Draft Bioregional Assessment.
Download the Draft Bioregional Assessment
Download Sierra Forest Legacy comments on the Draft Bioregional Assessment
January 15, 2013 -- Science Synthesis and Bioregional Assessment
The new planning rule requires a commitment to integrating the best available science into forest management plans. Here at Sierra Forest Legacy, we seek to ensure that forest management is guided by the most current science relative to the ecology of the region. The result of commitments made by the agency to convene a science panel to provide a baseline synthesis of the status of Sierra Nevada forest resources is now available in the Science Synthesis, produced by a team of scientists from the research branch of the Forest Service (Pacific Southwest Research Station, or PSW).
How to get involved:
Download the complete (13.3 MB) Science Synthesis to Support Land and Resource Management Plan Revision in the Sierra Nevada and Southern Cascades, or you can also download it by individual chapters from this FS website.
Comments will be accepted until May 1, 2013. Send to: Lenya N. Quinn-Davidson at firstname.lastname@example.org.
Also see Sierra Cascades Dialog sessions website for background documents about public involvement with Science Synthesis and Bioregional Assessment.
Join the Forest Service Living Assessment wiki (website) to provide online comments and feedback to the agency draft assessment that tracks the forest planning rule's 15 required content topics.
March 23, 2012
The Forest Service announced today the finalizing of the new forest planning rule. According to the agency, no significant changes were made from the draft rule published in May, 2011, however, clarifications were made for important issues, such as the use of the best available science. You can read the rule here, or at the Forest Service planning rule website, where you will also find a summary, FAQs, and additional information and documents pertaining to the rule.
Read the Forest Service press release announcing the final rule here.
Although there was widespread support for retention of the strong viability rule language from the 1982 version of the rule, no such viability rule now exists for wildlife. However, because of the strong commitment to utilizing the best available science, we believe that the new rule can be equally as protective for wildlife viability and biological diversity, if commitments for monitoring and adaptive management are kept. Public participation in new forest management plan development will be essential to ensure that these commitments are met, and that national forest management continues to evolve along with our increased scientific knowledge.
If we are to sustain the biological treasure that is the Sierra Nevada for posterity, we must take seriously the threats of climage change and loss of habitat and ecological processes that face the national forests of our mountain range. Sierra Forest Legacy's Conservation Strategy, along with GTR-220, An Ecosystem Management Strategy for Sierran Mixed-Conifer Forests, and the latest companion technical report, GTR-237, Managing Sierra Nevada Forests, are the right tools we will need to get off to a good start for forest planning in California.
January 26, 2012
Today the USDA Forest Service announced the release of the Final Programmatic Environmental Impact Statement (FPEIS) for the 2011 Planning Rule. In addition, the agency announced that three forests (the Inyo, Sequoia, and Sierra NFs) in California will be among the first nationally to implement the new rule in the process of revising their current forest plans as required under the National Forest Management Act, NFMA (forest plans must be revised every 15 years). Read more about this history and the current planning rule on the NFMA section of this website.
It is likely that all of the forest plans currently due for revision in California will be revised in accordance with the new rule, which will be finalized in early 2012. We are engaged in leading a coalition of conservation groups throughout California in the development of a conservation strategy for the 11 national forests of the Sierra Nevada that will ensure long term protection and conservation of the Sierra Nevada's unique and priceless biological heritage. We will continue to be actively engaged with the Forest Service throughout the collaborative process set out in the new rule, beginning with the three "early adopter" forests as they are now called, the Inyo, Sequoia, and Sierra NFs.
Due to the efforts of the Bush Administration in dismantling the 1982 forest planning regulations and replacing them with a watered down 2005 planning rule revision, National Forests throughout the Sierra Nevada came under serious threat of losing the key conservation provisions of the National Forest Management Act. The Forest Service sought to advance the plan revision process under a categorical exclusion from NEPA, or environmental analysis of possible significant impacts from new management directions. That would virtually eliminate public oversight of management of our public lands, and greatly erodes the long-standing NEPA process of environmental review. This, along with the administration's decimation of the conservation-focused 2001 Sierra Nevada Framework with its 2004 Framework revision, could leave the National Forests of the Sierra Nevada at risk of losing the amazing attributes that make them such unique global watersheds, recreation destinations, and significantly important ecosystems -- or at the least, leaving them significantly diminished.
In March, 2007, a court decision reversed the Bush administration's 2005 planning rule. In April 2008, however, the Planning Rule was released virtually unchanged, in spite of tens of thousands of comment letters opposing the revisions. Subsequently, the rule was found to be unlawful and overturned in federal court in June of 2009. Since then, the Forest Service has been developing a new rule and the accompanying environmental impact statement. [UPDATE: See Final Rule, here.]
Today we are working with a coalition of national conservation groups to provide the agency with a unified, comprehensive vision for science-based management of our national forests that will ensure their long term stability in the face of global climate change, and protection for rare and imperiled plants and wildlife. Click on this link to go the Conservation Strategy website.
Committee of Scientists report. 1999. Sustaining the People's Lands. This report has been taken down recently from the Forest Service's science website. We are working on getting a copy restored for public access to this foundational report.
Noon, B.R., K.S. McKelvey, and B.G. Dickson. 2009. Multispecies conservation planning on U.S. federal lands. Pages 51-84 in J.J. Millspaugh and F.R. Thompson, III, editors. Models for Planning Wildlife Conservation in Large Landscapes. Academic Press, New York.
Schultz, C.A., T.D. Sisk, B.R. Noon, and M.A. Nie. 2013. Wildlife conservation planning under the United States Forest Service's 2012 planning rule. The Journal of Wildlife Management. Online : 23 Jan 2013, DOI: 10.1002/jwmg.513